[NCUC-DISCUSS] Fwd: RrSG Draft White Paper: Registrant Protections in DNS Abuse Mitigation

[farzaneh badii]

Hi Bruna,

Here are some preliminary comments. We can work on them if you want to send
something on behalf of NCSG:

1. Thank you for focussing on protecting registrants when fighting with DNS
abuse. They are most of the time neglected.

2. They mention that the registrars are contributing to DNS abuse
"community mechanisms".We should be clear that we are not sure how NCSG and
noncommercials are included in these efforts. If they mean by community
effort you as being a part of DNS abuse institute advisory council or
Stephanie Perrin as the rep on the advisory council of PIR then I think
they should be clear about that. If they mean "community efforts" at ICANN
then I am not sure what they mean.

3. Under the Evidentiary section, this is not an appeals mechanism or a
pre-appeal mechanism. What they are describing is the evidence that the DNS
abuse complaints should include and is a part of the due process they need
to provide for the registrants. That section needs to be much more detailed
with a process on how the abuse reports are treated, what sort of evidence
they need from the complainant etc.

4. I have not heard the term "ombud". It is either Ombuds or Ombuds Person
or Ombuds Office. It's a good idea but they need to look into what they
mean by "binding" outcomes because usually Ombuds outcomes are not legally
binding - So the registrar binds itself by it?

5. Fundamental problem with this white paper is that it bases the
protection of registrants from fraudulent and frivolous DNS abuse
complaints (or just simply mistaken ones) by just considering ex post
dispute resolution and appeals mechanism. It is a good step forward but
that is not enough. Measures should be taken to reduce the number of
unfairly impacted domains before they actually happen. People have
businesses and websites and they rely on their domain name. A shut-down can
cost them a lot and affects them financially as well as operationally and
their activism and whatever service is time-sensitive.





Farzaneh


On Mon, Jun 28, 2021 at 10:28 AM Bruna Martins dos Santos <
bruna.mrtns at gmail.com> wrote:

> Hey all,
>
> Hope this email finds you well.
>
> RrSG just issued a white paper on DNS abuse mitigation that Ashley
> Heineman kindly sent to NCUC in order to gather any input from the
> Constituency. Given that this is a policy discussion that is more often
> discussed at the SG level and by the PC, I am also sharing the paper on our
> list in order to check whether anyone would like us to offer additional
> input to this initiative.
>
> The deadline Raphael set for NCUC is Thursday (01.07), so I believe we can
> adopt the same one.
>
> Best,
> Bruna
>
>
> ---------- Forwarded message ---------
> From: Raphael Beauregard-Lacroix <rbeauregardlacroix at gmail.com>
> Date: Mon, Jun 28, 2021 at 11:04 AM
> Subject: [NCUC-DISCUSS] Fwd: RrSG Draft White Paper: Registrant
> Protections in DNS Abuse Mitigation
> To: NCUC Discuss <ncuc-discuss at lists.ncuc.org>
>
>
> Dear all,
>
> The Registrar SG has drafted a white paper on DNS abuse mitigation and
> would like to know if we (NCUC) have any input to provide. See below for
> more info and attachment.
>
> Feel free to discuss in this thread by Thursday COB UTC.
>
> Thank you and have a nice day,
>
> ---------- Forwarded message ---------
> From: aheineman at godaddy.com <aheineman at godaddy.com>
> Date: Fri, Jun 4, 2021 at 8:08 PM
> Subject: RrSG Draft White Paper: Registrant Protections in DNS Abuse
> Mitigation
> To: rbeauregardlacroix at gmail.com <rbeauregardlacroix at gmail.com>
> Cc: Zoe Bonython <secretariat at icannregistrars.org>, Reg Levy <
> rlevy at tucows.com>, Luc SEUFER <lseufer at namespace.com>
>
>
> Dear Raphaël Beauregard-Lacroix,
>
>
>
> The RrSG DNS Abuse Subgroup drafted the attached White Paper discussing
> Registrant Protections in DNS Abuse Mitigation, centering on the issue of
> innocent registrants whose domains are impacted by DNS Abuse mitigation by
> a registrar (or registry, as the case may be).  The RrSG is looking to
> publish the paper around the time of ICANN 71, but wanted to give the NCUC
> the opportunity to provide comments in advance as we know this is an issue
> of interest to your members.  This paper is not time sensitive, so if you
> would like additional time, please let us know.  As additional background,
> the RrSG periodically drafts and publishes white papers for informational
> purposes, and this is our first attempt to better socialize our work with
> interested community members.
>
>
>
> Kindest regards,
>
>
>
> Ashley Heineman
>
> Chair, RrSG
>
>
>
>
>
>
> _______________________________________________
> Ncuc-discuss mailing list
> Ncuc-discuss at lists.ncuc.org
> https://lists.ncuc.org/cgi-bin/mailman/listinfo/ncuc-discuss
>
>
> --
>
> *Bruna Martins dos Santos *
>
> Advocacy Coordinator | Data Privacy Brazil Research
> <https://www.dataprivacybr.org/en/>
>
> Member | Coalizão Direitos na Rede <https://direitosnarede.org.br/>
> Chair | Non-Commercial Stakeholder Group at ICANN
> <https://gnso.icann.org/en/about/stakeholders-constituencies/ncsg>
> Co-Coordinator | Internet Governance Caucus  <https://igcaucus.org/>
>
> Twitter: @boomartins <https://twitter.com/boomartins> // Skype:
> bruna.martinsantos
> bruna at dataprivacybr.org and bruna.mrtns at gmail.com
>
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